Common use of Other Supporting Justifications Clause in Contracts

Other Supporting Justifications. This matching program supports compliance with the Payment Integrity Act of 2019 (PIIA) (31 U.S.C. §§ 3352 et seq.) which focuses on preventing improper payments to ensure funding is serving its intended purpose as first set out in E.O. 13520, Reducing Improper Payments and Eliminating Waste in Federal Programs, 74 FR 62201 (Nov. 25, 2009), which states the policies of federal programs that serve their intended beneficiaries provide public scrutiny of significant payment errors and eliminate the highest improper payments; establish accountability for reducing improper payments; and coordinate federal, state, and local government action in identifying and eliminating improper payments, and implementing guidelines in OMB Memorandum M-18-20, Transmittal of Appendix C to Circular A-123, Requirements for Payment Integrity Improvement, (June 26, 2018). Payment integrity is a top priority, and OMB guidance provides the framework to reduce the administrative burden, allowing agencies to focus on identifying, assessing, prioritizing, and responding to payment integrity risks and the underlying causes of improper payments. See OMB Memorandum M-21-19, Transmittal of Appendix C to Circular A-123, Requirements for Payment Integrity Improvement (March 5, 2021). HUD specific statutory and regulatory requirements further justify the matching program and the analysis of employment and income reporting. HUD must establish procedures to ensure that families applying for or receiving assistance provide complete and accurate income information to PHAs and MF business partners. HUD must randomly, regularly, and periodically select a sample of families and obtain information from external agency data sources pertaining to the individuals within the families only for the purpose of verifying incomes, data concerning unemployment compensation, and Federal income taxes in order to determine eligibility of families for benefits (and the amount of benefits, if any). 42 U.S.C. § 1437f(k). HUD program administrators must use accurate income amounts to determine housing rental assistance. See 24 CFR § 5.659 and Chapter 5, Section 3: Verification of the Occupancy Requirements of Subsidized Multifamily Housing Programs, 4350.3 REV-1. For the public housing and tenant-based Section 8 programs, PHAs must use accurate income amounts to determine housing rental assistance and verify a family’s annual income and other factors that affect the determination of adjusted income or income-based rent. 24 CFR §§ 960.259 and 982.516. HUD estimates the total subsidy error associated with incorrect or fraudulent reporting to be approximately $185 million from July 2022 through July 2023 and estimates that 519,419 households have incorrectly reported income. HUD also estimates that approximately 19 percent of the households participating in PIH and MF Housing programs, respectively, may not have disclosed all wage, employment, unemployment compensation benefits, or Social Security benefits. The NDNH is a centralized database of wage and employment information and, as such, provides an effective and efficient means to obtain information to assist HUD in identifying subsidy errors. The matching program will assist HUD in detecting fraud, waste, and abuse and enhancing program integrity by providing useful information on the employment status and wages of HUD program applicants and recipients, specifically: 1) those who are employed with the federal government; 2) those who are employed in another state, including those who have been rehired by a previous employer after having been separated from such prior employment for at least 60 consecutive days, and 3) those whose information is not readily available through the State Directory of New Hires, state workforce agencies, or other data reporting systems. 42 U.S.C. § 653a(a)(2). The positive results of the previous matching programs between HUD and OCSS further justify the proposed matching program. See section II.B and Appendix B.